Model for environmentally graduated contributions – here are the expected criteria

One of the pillars of the producer responsibility is that packaging reduction and environmentally friendly design must pay off for companies. Therefore, it will also be a requirement that the costs you have to pay will be environmentally graduated the when producer responsibility comes into force in July 2025.

The Danish Environmental Protection Agency has now made their recommendation for legislation in this area, and we therefore expect the following points to be included in the final legislation:

• Producers must report data on their packaging in 11 material categories (fractions).
• Each material category is divided into different levels (rates)
  • 4 of the categories (flexible plastics, hard plastics, hard PET, and foam plastics) are divided into three levels: low/medium/high.
  • 6 of the categories (food and drinks cartons, glass, cardboard, paper, steel and other ferrous packaging and aluminium) are divided into two levels: low/high
  • 1 of the categories (wood) is not divided into levels.
• The PRO (Producer Responsibility Organisation) must provide each producer, who places one or more high-level packaging on the market, with a malus (additional cost) in the form of 35 % of each producer's calculated operational costs for waste management of all of its products falling below the high level.
• Packaging may consist of main and sub-components. Subcomponents are categorised into the same material category as the main component. The packaging is categorised by the dominant material based on weight.

Read more about the individual criteria in the Danish Environmental Protection Agency's draft executive order here (for members). 

The criteria for when you should pay more or less for your packaging waste will be determined by the state in an executive order, which will be submitted for consultation at the end of May 2024. The environmental modulation will enter into force on 1 July 2025, and will not apply to the upcoming registration and reporting in 2024 - read more about registration in 2024 here.

See the timetable for implementation of the producer responsibility here.